BANK OF AMERICA, SARS, THE CITIZENSHIP BY INVESTMENT SCANDAL, CARIBBEAN GALAXY/CHINA AND JEFFREY EPSTEIN

A memorandum prepared for the United States Senate, regarding the unusually late filing of Suspicious Activity Reports, or SARs, by BANK OF AMERICA, which were reportedly filed years after $140m of suspicious payments to JEFFREY EPSTEIN, has recommended that the matter be turned over to the Financial Crimes Enforcement Network (FinCEN), to investigate the bank's conduct. Apparently, the bank failed to file the SARs until six months after his indictment and suicide in Federal Prison, and after a civil RICO lawsuit against Epstein's estate was filed. Who made that command decision, we wonder, Compliance or the executives in charge of the accounts?

If there is a corporate culture at any bank, to delay filing of a SAR for a valued or lucrative client until possible misconduct is publicly exposed, then questions should be raised, regarding the effectiveness of the bank's risk-based compliance program. Were critical compliance decisions being trumped by account executives responsible for for the client, due solely to revenue considerations?

We bring this up because, with the huge amount of publicity over the unfolding fraud, money laundering and corruption scandal over Caribbean Citizenship, the bank continues to maintain correspondent accounts for indigenous East Caribbean financial institutions that service CBI/CIP programs. While the law prohibits us from accessing any information about Sars filed, regarding those accounts, especially whether the reporting of information deemed suspicious is inordinately delayed, if such conduct has occurred regarding CBI accounts, resulting in belated notification to regulators and law enforcement agencies, it should be investigated as a National Security matter, due to China's known involvement. We urge the U.S. Senate to note our concerns.